INCOME TAXES

We conduct business globally and report our results of operations in a number of foreign jurisdictions in addition to the United States. Our reported tax rate is generally lower than the U.S. federal statutory rate as the income tax rates in the foreign jurisdictions in which we operate are generally lower than the U.S. statutory tax rate.

During the three months ended October 1, 2016 and September 26, 2015, we reported an income tax provision of $3.0 million and $3.7 million, respectively, representing effective tax rates of 13.2% and 22.4%, respectively. For the six months ended October 1, 2016 and September 26, 2015 we reported an income tax provision of $3.3 million and $5.6 million, respectively, representing effective tax rates of 25.8% and 30.7%, respectively.

The decrease in our income tax provision for both the three and six months ended October 1, 2016, as compared to the prior year periods, was primarily due to changes in the jurisdictional mix of earnings. During the six months ended October 1, 2016, the income tax provision includes a discrete tax provision of $1.4 million for an uncertain tax position that was triggered by a reduction in workforce in one of our foreign subsidiaries during the first quarter of fiscal 2017. We had previously negotiated a tax holiday under which we were required to maintain certain levels of headcount for a multi-year period. During the first quarter of fiscal 2017, as a result of a reduction in workforce, we were unable to satisfy the required headcount levels and became subject to a potential tax assessment related to historical tax years. The tax provision associated with this tax reserve establishment was partially offset by a tax benefit for the release of a tax reserve due to the expiration of statute of limitations during the second quarter of fiscal 2017. We are in a three year cumulative loss position in the U.S. and, accordingly, maintain a valuation allowance against our U.S. deferred tax assets. We also maintain a valuation allowance against certain foreign deferred tax assets which we have concluded are not more-likely-than-not realizable.

The income tax provision for the six months ended September 26, 2015 includes a discrete tax provision of $1.0 million to increase the deferred tax liability related to amortizable goodwill as a result of the statutory capital gains tax rate in Puerto Rico increasing from 15% to 20%.

Unrecognized Tax Benefits

Unrecognized tax benefits represent uncertain tax positions for which reserves have been established. As of October 1, 2016 we had $3.7 million of unrecognized tax benefits, of which $1.8 million would impact the effective tax rate, if recognized. As of April 2, 2016, we had $2.5 million of unrecognized tax benefits, of which $0.6 million would impact the effective tax rate, if recognized.

During the six months ended October 1, 2016, our unrecognized tax benefits were increased by $1.3 million due to the establishment of a tax reserve for the potential tax assessment associated with a foreign subsidiary’s historical tax years as a result of a reduction in workforce which impacts a previously negotiated tax holiday.

The following table summarizes the activity related to our gross unrecognized tax benefits for the fiscal periods ended October 1, 2016 and April 2, 2016:



(In thousands)	Six Months Ended October 1, 2016			Year Ended April 2, 2016
Beginning balance	$	2,523		$	7,070
Additions for tax positions of prior years	1,320			340
Reductions of tax positions	—			(4,158		)
Closure of statute of limitations	(165		)	(729		)
Ending balance	$	3,678		$	2,523

As of October 1, 2016, we anticipate that the liability for unrecognized tax benefits for uncertain tax positions could change by up to $1.6 million in the next twelve months, as a result of closure of various statutes of limitations or settlements.

Our historic practice has been and continues to be to recognize interest and penalties related to Federal, state and foreign income tax matters in income tax expense. Approximately $0.4 million of gross interest and penalties were accrued at October 1, 2016 and April 2, 2016 and is not included in the amounts above. Tax expense associated with accrued interest and penalties was insignificant for the six months ended October 1, 2016.

We conduct business globally and, as a result, file consolidated and separate Federal, state and foreign income tax returns in multiple jurisdictions. In the normal course of business, we are subject to examination by taxing authorities throughout the world. With a few exceptions, we are no longer subject to U.S. federal, state, or local income tax examinations for years before 2012 and foreign income tax examinations for years before 2011.